Ultraviolet (UV) radiation is widely used across industry, healthcare, laboratories, manufacturing, and research. Yet despite being well understood scientifically, UV exposure remains one of the most consistently underestimated workplace hazards.
Many organisations assume UV only becomes a concern after an incident. In reality, both UK regulation and enforcement practice place the duty firmly on anticipating and controlling exposure before harm occurs – whether that harm is immediate or delayed by many years.
This article explains why proactive UV risk management matters, how it reduces short-term enforcement risk, and why it is essential for managing long-term health and liability concerns.
UV light exposure is a known, regulated hazard
In the UK, exposure to artificial UV radiation is covered primarily by the Control of Artificial Optical Radiation at Work Regulations 2010, alongside wider duties under the Health and Safety at Work Act. These regulations do not require an injury to occur before action is taken. They require employers to:
- Identify sources of UV radiation
- Assess potential exposure against recognised exposure limit values
- Apply suitable controls
- Provide information and training
- Keep evidence that risks are being actively managed
From a regulatory perspective, UV exposure is considered foreseeable and preventable.
Short term risk: inspections, enforcement, and incidents
In practice, UV exposure is rarely the sole reason for a visit by the Health and Safety Executive (HSE). However, it is frequently identified during unannounced inspections, machinery assessments, COSHH reviews, or incident investigations.
When UV hazards are visible — open sources, accessible enclosures, bypassed interlocks, lack of signage, or staff unfamiliar with the risks – inspectors will challenge them immediately. The difference between a minor issue and formal enforcement often comes down to evidence.
Organisations that can demonstrate a site-specific UV risk assessment, consideration of exposure limits, verified engineering controls and documented training are far less likely to face enforcement action, even if UV was not the original focus of the inspection. Those that rely on assumptions, supplier assurances, or generic assessments often find UV becomes an unexpected compliance issue.
Proactive assessment reduces inspection and enforcement risk.
Waiting for an incident is already too late
A common misconception is that UV only matters once someone is injured. From a regulatory standpoint, that logic does not hold. An incident involving UV exposure – particularly eye injury or burns, raises immediate questions:
- Was the risk assessed in advance?
- Were exposure levels understood?
- Were controls adequate?
- Was training sufficient?
If the answer to any of these is unclear, enforcement can escalate quickly, especially where injuries are reportable under RIDDOR.
The long term risk: the silent exposure problem
While short-term injuries attract attention, long-term UV exposure presents a different and often overlooked risk. UV harm can be cumulative, symptomless for long periods, and linked to conditions that emerge years or decades later, such as:
- Cataracts and retinal damage
- Chronic eye conditions
- Skin cancers
- Accelerated skin ageing
The delayed nature of these outcomes does not reduce employer responsibility. Legally, the key question is not when harm appears, but whether the risk was known or reasonably foreseeable at the time of exposure. For UV radiation, the scientific evidence and regulatory framework have been established for many years. As a result, future claims or investigations will focus on whether exposure was properly assessed and controlled at the time.
Why intermittent exposure still matters
One of the most common failures in UV risk management is underestimating short, repeated exposures. Maintenance tasks, fault-finding, set-up activities, cleaning, and occasional overrides often fall outside routine assessments. Individually, these exposures may appear trivial. Over time, they can accumulate significantly. Without records, measurements, or documented reasoning, organisations are left with little defence if concerns emerge years later.
What proactive UV management actually looks like
Effective UV risk management does not require complexity, but it does require intent.
Key elements include:
- Assessing exposure properly – measuring and assessing personal exposure, rather than assumption.
- Focusing on non-routine tasks – maintenance and abnormal operation are where risk most often appears.
- Controlling exposure by design – enclosures, shielding, interlocks, and access control should take priority over PPE.
- Training that reflects real risk – including cumulative exposure and long-term health effects, not just immediate injury.
- Keeping records – risk assessments, exposure evaluations, training records, and control verification all become critical over time.
These steps protect workers, but they also protect organisations from future regulatory and risk.
If you’d like to discuss an on-site UV measurement and assessment survey, to help you understand
A hazard that spans decades
UV exposure is unusual in that it can cause immediate injury or harm that only becomes visible many years later – and the legal duty to manage that risk exists long before either occurs.
Proactive assessment and training are not about over-compliance. They are about meeting a clear regulatory expectation and avoiding problems that are far harder to manage retrospectively.
Addressing it proactively protects people now, reduces enforcement risk, and provides a defensible position for the future.
UV exposure is one of the few workplace hazards where the consequences of inaction may not appear until long after the opportunity to manage the risk has passed.